Response to consultation on Guidelines on preventing the abuse of funds and certain crypto-assets transfers for ML/TF (Travel rule Guidelines)

Question 1. Do you agree with the proposed provisions? If you do not agree, please explain how you think these provisions should be amended, and set out why they should be amended. Please provide evidence of the impact these provisions would have if they were maintained as drafted'?

Dear Sir/ Madam, 

please find attached the response from the Digital Currencies Governance Group (DCGG) to the EBA consultation paper 2023/35. DCGG represents digital assets issuers and service providers in the EU and the UK. Our Members include amongst others Tether - a stablecoin issuer, Ledger - a leading security technology provider for self-custody, and Bitfinex - a centralised crypto-assets exchange. 

We remain at your disposal for any questions you might have and look forward to discuss our response with you further. 

Best regards

Jörn-Jakob Röber

Head of EU Policy of DCGG

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